arizona state board of education a-f accountability ad hoc ... a... · 10/7/2016 · arizona state...

Arizona State Board of Education A-F Accountability Ad Hoc Committee Meeting October 7,2016

Item #2 EXECUTIVE SUMMARY Page 1 of 1

Contact Information: Dr. Karol Schmidt, Executive Director, State Board of Education

Issue: Presentation, discussion and review of the consensus conceptual framework and considerations for an A-F school accountability plan as adopted by the State Board of Education at the September, 2016 meeting

Action/Discussion Item Information Item

Background and Discussion At the September 2016 Board meeting, Vice President Tim Carter introduced a revised conceptual framework for Arizona’s new A-F School Accountability plan. The Board voted to amend the conceptual framework to add seven additional conceptual considerations for the A-F Ad Hoc Advisory Committee. The revised conceptual framework is attached. The consensus conceptual framework is mindful of ESSA requirements, as well as possible requirements from the regulations which are still being finalized. The revised model separates K-8 from 9-12 for further clarity and recognition of indicators unique to 9-12. The indicators reflect the opportunity to measure the quality of a school and its effectiveness across a broader range than in the past, as recognized by both the Board’s legislation on SB 1430 and ESSA. These indicators are intended to provide direction to the Board’s ad hoc and the Department’s technical advisory groups to further develop specific multiple measures of the indicators. The percentages are intended to provide guidance on weighting, reflective of the Board’s values, of the various indicators. It is understood that these guiding weights are subject to change based on modeling by the Department’s technical advisory groups, but that the embedded ranking of the indicators reflecting the Board’s values in the consensus conceptual design should be maintained. Recommendation to the Committee Discussion item only.

CONSENSUS CONCEPTUAL DESIGN FOR THE A-F SCHOOL ACCOUNTABILITY SYSTEM

Guidance on weight

Indicators K-8 ESSA

40% Proficiency, Statewide Assessment

X X

40% Growth, Statewide Assessment

X X

10% Proficiency and Growth, English Language Learners

X X

10% Acceleration / Readiness Measures

X X

Guidance on weight

Indicators 9-12 ESSA

40% Proficiency, Statewide Assessment

X X

20% Growth, Statewide Assessment

X

15% High School Graduation Rate

X X

15% College and Career Readiness

X X

10% Proficiency and Growth, English Language Learners

X X

Conceptual considerations:

• A menu of assessments is preferred. • Multiple criteria/measures are important. • Multiple indicators are important. • While conforming to federal and state law, local decision making should be

preserved and multiple options available. • In general, the students shall be the unit of analysis. • With the use of end of course assessments, no single high stakes exam shall be

required. • The weights or guidance may be altered by the ad hoc committee as potentially

approved by the State Board of Education. • Proficiency shall be the primary criteria. • One A-F accountability system shall be designed that meets both federal and

state requirements. • A review of the issue of character as a component shall be considered. • The bottom 25% shall be removed as a separate subgroup and the calculation

shall be included as a growth calculation.

Arizona State Board of Education A-F Accountability Ad Hoc Committee Meeting October 7, 2016



Issue: Presentation, discussion and possible action regarding identifying short and long-term goals pursuant to Every Student Succeeds Act: proficiency on tests, English-language proficiency and graduation rates.


Background and Discussion Proposed regulation §200.13 of the Every Student Succeeds Act (ESSA) would incorporate into regulation the following items:

• State-designed long-term goals and measurements of interim progress for academic achievement,

• Graduation rates, and • Progress in achieving English language proficiency.

Governor Ducey supports a framework titled “Education Matters Arizona” that ensures a world class 21st-century education. The Committee should consider the following measures that ensure student success from kindergarten through post-secondary education when creating short and long-term goals:

• Percentage of preschool enrollment as measured by kindergarten success • Percentage of third grade readers as measured by students reading at grade

level by the end of third grade • Percentage of students demonstrating success in eighth grade mathematics as

measured by students who are proficient in Algebra skills by the end of eighth grade

• Percentage of students who complete high school and/or youth enrollment in school or by entering the workforce as measured by college and career readiness

• Percentage of postsecondary attainment and/or college-going students as measured by students attaining a degree, certificate or credential

Another item for the Committee to consider is Governor Ducey’s initiative titled Achieve60AZ which focuses on ensuring that 60 percent of Arizonans ages 25 and older have a certificate or college degree by the year 2030. This focus on college and career readiness is a priority of both the Governor and the Board and should be included in the short and long-term goals of the Committee’s recommendation. The Progress Meter supports a shared vision for a world-class education in Arizona and was adopted by a wide array of stakeholders including the State Board of Education, the Arizona Department of Education and the Arizona Governor’s Office of Education

Arizona State Board of Education A-F Accountability Ad Hoc Committee Meeting October 7,2016


Innovation. Consisting of eight criteria, the Progress Meter provides a roadmap to measure progress and celebrate successes through collective action on: post-secondary attainment, college going, opportunity youth, high school graduation, 8th grade math, 3rd grade reading, preschool enrollment and teacher pay. This framework should be used as a consideration for the development of the Committee’s recommendation. Recommendation to the Committee It is recommended that the Committee identify short and long-term goals consistent with ESSA requirements for recommended adoption by the State Board of Education.

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PROPOSED REGULATIONS - https://www2.ed.gov/policy/elsec/leg/essa/nprmaccountabilitystateplans52016.pdf

Section 200.13 Long-term goals and measurements of interim progress

Statute: Section 1111(c)(4)(A)(i)(I) and (c)(4)(A)(ii) of the ESEA, as amended by the ESSA, requires each State to establish ambitious long-term goals, and measurements of interim progress toward those goals, for specific indicators, for all students and for each subgroup of students described in section 1111(c)(2): economically disadvantaged students, students from major racial and ethnic groups, children with disabilities, and English learners. These goals and measurements of interim progress must be set, at a minimum, for improved academic achievement (as measured by proficiency on State assessments in reading/language arts and mathematics), for improved high school graduation rates (as measured by the four-year adjusted cohort graduation rate), and for increases in the percentage of English learners making progress toward English language proficiency (as measured by the English language proficiency assessments required in section 1111(b)(2)(G)) within a State-determined timeline. In addition, States may establish long-term goals and measurements of interim progress for graduation rates as measured by extended-year adjusted cohort graduation rates, but such goals and interim measurements must be more rigorous than those set based on the four-year adjusted cohort graduation rate.

Section 1111(c)(4)(A)(i)(II) also requires that the State’s ambitious long-term goals

for achievement and graduation rates use the same multi-year length of time for all students and each subgroup of students. This is explained further below.

Finally, section 1111(c)(4)(A)(i)(III) specifies that a State’s goals for subgroups

of students must take into account the improvement needed among subgroups that must make greater progress in order to close achievement and graduation rate gaps in the State. Current Regulations: Various sections of the current title I regulations describe the role of goals and annual measurable objectives (AMOs) in the State accountability system required by the ESEA, as amended by the NCLB, and require each State to establish a definition of AYP. These sections essentially repeat the NCLB, with the exception of §200.19 regarding the four-year adjusted cohort graduation rate, which was added to the title I regulations in 2008.

Proposed Regulations: Proposed §200.13 would primarily incorporate into regulation the statutory requirements under the ESEA, as amended by the ESSA, for State-designed long-term goals and measurements of interim progress for academic achievement, graduation rates, and progress in achieving English language proficiency. The proposed regulations also would clarify certain provisions to support effective State and local implementation of the statutory requirements.

Goals for Academic Achievement and Graduation Rates

Proposed §200.13 would require each State to--

• Establish ambitious long-term goals and measurements of interim progress for

https://www2.ed.gov/policy/elsec/leg/essa/nprmaccountabilitystateplans52016.pdf

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academic achievement that are based on grade-level proficiency on the State’s academic assessments and set separately for reading/language arts and mathematics;

• In setting long-term goals and measurements of interim progress for academic

achievement, apply the same high standards of academic achievement to all students and each subgroup of students, except students with the most significant cognitive disabilities who are assessed based on alternate academic achievement standards, consistent with section 1111(b)(1);

• Establish ambitious long-term goals and measurements of interim progress for

graduation rates that are based on the four-year adjusted cohort graduation rate and, if a State chooses to use an extended-year rate as part of its Graduation Rate indicator under proposed §200.14, the extended-year adjusted cohort graduation rate, except that goals based on the extended-year rate must be more rigorous than goals based on the four-year rate;

• Set long-term goals and measurements of interim progress for academic achievement

and graduation rates for all students and separately for each subgroup of students that expect greater rates of improvement for subgroups that need to make more rapid progress to close proficiency and graduation rate gaps in the State; and

• Use the same multi-year timeline in setting long-term goals for academic achievement

and graduation rates for all students and for each subgroup (e.g., if the goal for all students is to improve academic achievement by a certain percentage over 10 years, then the goal for children with disabilities must also be set over 10 years, even if the subgroup is expected to improve by a greater percentage relative to all students over that timeframe).

Goals for Progress in Achieving English Language Proficiency

The proposed regulations would require each State to-- • Establish ambitious long-term goals and measurements of interim progress for English

learners toward attaining English language proficiency, as measured by the State’s English language proficiency assessment, that set expectations for each English learner to make annual progress toward attaining English language proficiency and to attain English language proficiency; and

• Determine the State’s long-term goals and measurements of interim progress for English

learners by developing a uniform procedure for setting such goals and measurements of interim progress that would be applied consistently to all English learners in the State, must take into account the student’s English language proficiency level, and may also consider one or more of the following student-level factors at the time of a student’s identification as an English learner: (1) time in language instruction educational programs; (2) grade level; (3) age; (4) Native language proficiency level; and (5) limited or interrupted formal education, if any.

Reasons: The proposed regulations would primarily replace obsolete provisions relating to goals and progress measures within State accountability systems to reflect changes required by the ESEA, as amended by the ESSA. In addition, the proposed regulations would clarify

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requirements related to goals for academic achievement, particularly for students with the most significant cognitive disabilities, as well as goals for English learners toward attaining English language proficiency.

Goals for Academic Achievement and Graduation Rates

Under section 1111(b)(2)(B)(ii), State assessments must provide information to students, parents, and educators about whether individual students are performing at their grade level. This determination provides valuable information about whether a student is receiving the support he or she needs to meet the challenging State academic standards and is on track to graduate ready to succeed in college and career, and if not, to help identify areas in which the student would benefit from additional support. This information also helps States and LEAs identify statewide proficiency gaps when establishing the State’s goals and measurements of interim progress, as required under section 1111(c)(4)(A)(i)(III). Goals based on grade-level proficiency would provide consistency across the accountability system, as the statute requires the Academic Achievement indicator described in section 1111(c)(4)(B)(i)(I) to be based on a measure of proficiency against the challenging State academic standards. Therefore, the proposed regulations would clarify that the long-term goals a State establishes must be based on a measure of grade-level proficiency on the statewide assessments required under section 1111(b)(2) and must be set separately for reading/language arts and mathematics.

Section 1111(b)(1) also requires that all students be held to the same challenging

State academic standards, except for students with the most significant cognitive disabilities who are assessed based on alternate academic achievement standards, as permitted under section 1111(b)(2)(D)(i). To ensure that all students are treated equitably and expected to meet the same high standards, and that all schools are held accountable for meeting these requirements, proposed §200.13 would clarify that long-term goals must be based on the same academic achievement standards and definition of “proficiency” for all students, with the exception of students with the most significant cognitive disabilities who take an alternate assessment aligned with alternate academic achievement standards.

Finally, to provide relevant, meaningful information to districts, schools, and the public about the level of performance and improvement that is expected, proposed §200.13 would require a State to set long-term goals and measurements of interim progress for graduation rates that are based on the four-year adjusted cohort graduation rate, as well as the extended-year adjusted cohort graduation rate if such a rate were used in the State’s Graduation Rate indicator described in section 1111(c)(4)(B)(iii). Given that the graduation rate could impact whether a school is identified for support and improvement, and related interventions, it is critical to require the State to set long-term goals and measurements of interim progress for this measure in order to establish clear expectations and support all schools in the State in increasing the percentage of students graduating high school.

Goals for Progress in Achieving English Language Proficiency

Because the requirement for progress in achieving English language proficiency goals has been added to title I in the ESEA, as amended by the ESSA, we propose to explain and clarify how States can meet this requirement in proposed §200.13. For English learners to

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succeed in meeting the challenging State academic standards, it is critical for these students to attain proficiency in speaking, listening, reading, and writing in English, as recognized in section 1111(b)(1)(F), including the ability to successfully make academic progress in classrooms where the language of instruction is English, as recognized in the definition of “English learner” in section 8101(20). For these reasons, proposed §200.13 would clarify that States’ long-term goals must include both annual progress toward English language proficiency and actual attainment of English language proficiency for all English learners.

Recent data have highlighted the growing numbers of school-aged English learners,

particularly in States and LEAs with relatively little experience in serving such students previously. The Census Bureau’s American Community Survey (ACS) data from 2013 show that California, Florida, Illinois, New York, and Texas enroll 60 percent of the Nation’s English learners, but the growth rate in the English learner population in other States has exceeded that of these five. For example, ACS data show that from 2010 to 2013, the English learner population increased by 21 percent in West Virginia, 13 percent in Hawaii and North Dakota, and 12 percent in Iowa. In addition, some States have experienced large increases of certain English learner subgroups over a short period of time. Alaska, the District of Columbia, New Hampshire, Oklahoma, South Dakota, Iowa, Maine, and Nebraska all experienced more than a 16-percent increase in their immigrant population during the 2010 to 2013 timeframe.

Given the diversity of the English learner population, illustrated in the examples

above, a reasonable timeframe for schools to support one English learner in attaining proficiency in English may be too rigorous or too lenient an expectation for another English learner. Setting the same long-term goals and measurements of interim progress for all English learners in the State may fail to account for these differences in the English learner population and would result in goals that are inappropriate for some students. Furthermore, the time it takes an English learner to attain proficiency can be affected by multiple factors, such as age, level of English proficiency, and educational experiences in a student’s native language.1 Thus, proposed

§200.13(c) would require States to consider students’ English language proficiency level in setting goals and measurements of interim progress and allow the consideration of additional research-based student factors. The list of student characteristics in proposed §200.13 is based not only on research but also on input from grantees and experts during administration of the former title III requirement for annual measurable achievement objectives (AMAOs). The ESEA, as amended by the NCLB, required that those AMAOs (which included progress toward and attainment of English language proficiency) reflect the amount of time an individual child had been enrolled in a language instruction educational program. Researchers, however, have found that the other factors outlined in proposed §200.13 are important factors that also should be included in setting goals for progress or proficiency.2

For these reasons, proposed §200.13(c) would require each State to establish a uniform procedure for setting long-term goals and measurements of interim progress for English learners that can be applied consistently and equitably to all English learners and schools with such students for accountability purposes, and that consider a student’s English

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language proficiency level, as well as additional research-based student characteristics at a State’s discretion (i.e., time in language instruction educational programs, grade level, age, native language proficiency level, and limited or interrupted formal education) in determining the most appropriate timeline and goals for attaining English language proficiency for each English learner, or category of English learner. Though the State’s procedure must be consistently applied for all English learners and consider the same student-level characteristics determined by the State, this approach would allow differentiation of goals for an individual English learner, or for categories of English learners that share similar characteristics, based on English language proficiency level, as well as factors such as grade level and educational background, thereby recognizing the varied needs of the English learner population.

Finally, proposed §200.13 would require a State’s long-term goals to expect each

English learner to attain English language proficiency within a period of time after the student’s identification as an English learner. This period of time could be informed by existing academic research on the typical time necessary for English learners to attain English language proficiency,3 and we encourage States to consider the requirement in section 3121(a)(6) of the ESEA, as amended by the ESSA, that subgrantees receiving title III funds report the number and percentage of “long-term” English learners (i.e., those that do not attain English language proficiency within five years of initial classification), in order to align the related title I and title III requirements. The long-term goals established by each State would not change the SEA and LEA’s obligation to assist individual English learners in overcoming language barriers in a reasonable period of time. Given these considerations, we are particularly interested in receiving comments on whether, in setting ambitious long-term goals to achieve English language proficiency, States would be better able to support English learners if the proposed regulations include a maximum State-determined timeline, and if so, what the maximum timeline should be--including any research or data to support the timeline--in order to ensure that State accountability systems effectively promote progress in attaining English language proficiency for these students.

1 See, for example, Collier, V. P. (1995). “Acquiring a second language for school.” Directions in Language & Education, 1(4); García-Vázquez, E., Vázquez, L. A., López, I. C., & Ward, W. (1997). “Language proficiency and academic success: Relationships between proficiency in two languages and achievement among Mexican-American students.” Bilingual Research Journal, 21(4), 334-347; and Center for Public Education (2007). “Research Review: What research says about preparing English language learners for academic success,” pp. 6-7. 2 See, for example, Cook, G., Linquanti, R., Chinen, M., & Jung, H. (2012). “National evaluation of Title III implementation supplemental report—Exploring approaches to setting English language proficiency performance criteria and monitoring English learner progress.” U.S. Department of Education, Office of Planning, Evaluation, and Policy Development, Policy and Program Studies Service, pp. 68-69. 3 See, for example, Hakuta, K., Goto Butler, Y., & Witt, D. (2000). “How long does it take English learners to attain proficiency?” University of California Linguistic Minority Research Institute Policy Report 2000-1; MacSwan, J., & Pray, L. (2005). “Learning English bilingually: Age of onset of exposure and rate of acquisition among English language learners in a bilingual education program.” Bilingual Research Journal, 29(3), 653-678; Motamedi, J.G. (2015). “Time to reclassification: How long does it take English language learners in the Washington Road Map school districts to develop English proficiency?” U.S. Department of Education, Institute of Education Sciences; and Slavin, R. E., Madden, N. A., Calderón, M. E., Chamberlain, A., & Hennessy, M. (2011). “Reading and language outcomes of a five-year randomized evaluation of transitional bilingual education.” Educational Evaluation and Policy Analysis, 33 (1), 47-58.

Post-Secondary

Attainment

College Going

Opportunity Youth

High School

Graduation

8th

Grade Math

3rd

Grade

Reading

Preschool

Enrollment

Teacher Pay

ExpectMoreArizona.org/Progress

http://www.expectmorearizona.org/progress

The Arizona Education Progress Meter represents key milestones on the path to improving educational opportunities and outcomes for all Arizonans. Progress made in each area will ultimately create a more prosperous economy, ensure students have the knowledge and credentials necessary for good jobs and improve the civic health of communities. The indicators include the following data points, with information available at the state and county levels on most measures:

Postsecondary Attainment: % of Arizona residents who have completed a 2-or 4-year degree or received a non-degree credential. (U.S. Census Bureau’s

American Community Survey, 2014 1-year PUMS Person File and the Arizona Board of Regents estimate of the Arizona adult population 25-64 years of age with a certificate but no greater education award, 2016)

College Going: % of Arizona high school graduates attending a post-secondary institution. (Arizona Board of Regents and National Center for Education

Statistics) Opportunity Youth: % of youth 16-24 in school or working. (U.S. Census Bureau, 2014 1-year PUMS Person File)

High School Graduation: % of Arizona high school students graduating in 4 years. (AZ Department of Education, 2013)

8th Grade Math: % of Arizona 8th grade students proficient or highly proficient on AzMERIT math. (Arizona Department of Education, 2014-15 AzMERIT results)

3rd Grade Reading: % of Arizona 3rd grade students proficient or highly proficient in reading on AzMERIT English language arts. (Arizona Department of

Education, 2014-15 AzMERIT results) Preschool Enrollment: % of Arizona 3 and 4 year olds enrolled in preschool, including public, private and homeschool settings. (U.S. Census Bureau, 2014 1-

year PUMS Person File. Definition: Preschool includes public, private or homeschool settings) Teacher Pay: Median Arizona elementary teacher salary as compared to the national median teacher salary. (Bureau of Labor Statistics, Occupational

Employment Statistics, U.S. Census Bureau)

The Arizona Education Progress Meter is endorsed by:

• Arizona Association of School Business Officials • A for Arizona • Arizona Board of Regents • Arizona Business & Education Coalition • Arizona Chamber of Commerce and Industry • Arizona Charter School Association • Arizona College Access Network • Arizona Commission for Postsecondary Education • Arizona Community Foundation • Arizona Department of Education • Arizona Education Association • Arizona GEAR UP • Arizona Hispanic Chamber of Commerce • Arizona School Administrators • Arizona School Boards Association • Arizona State Board of Education • Center for the Future of Arizona • Children’s Action Alliance • College Success Arizona • East Valley Partnership • Expect More Arizona

• First Things First • Governor’s Office of Education • Greater Flagstaff Chamber of Commerce • Greater Phoenix Chamber of Commerce • Greater Phoenix Economic Council • Greater Phoenix Leadership • Greater Yuma Economic Development Corp • Helios Education Foundation • New Schools for Phoenix • Northern Arizona Leadership Alliance • Read On Arizona • Rodel Foundation of Arizona • Social Venture Partners Arizona • Southern Arizona Leadership Council • Stand for Children – Arizona • Sun Corridor, Inc. • Tucson Metro Chamber • Tucson Hispanic Chamber of Commerce • United Way of Northern Arizona • United Way of Tucson and Southern Arizona • Valley of the Sun United Way

Arizona State Board of Education A-F Accountability Ad Hoc Committee Meeting October 7, 2016



Issue: Presentation, discussion and possible action regarding a draft A-F school accountability plan for K-8, recommendations regarding potential modeling by the Arizona Department of Education (ADE), review by the ADE advisory group, and next steps in developing a new draft A-F school accountability plan for K-8


Background and Discussion Proposed regulation §200.14 of the Every Student Succeeds Act (ESSA) would incorporate into regulation that states include, at a minimum, four distinct indicators for each school that measure performance for all students and separately for each subgroup of students. The indicators must include:

• Grade-level proficiency on the reading/language arts and mathematics statewide assessments

• Student growth for elementary students on the statewide assessments • High school graduation rates • English language proficiency • School quality or student success indicators

The measures within the indicators must be:

• Collected statewide • Research-based • Valid and reliable • Disaggregated by subgroup • Result in meaningful differentiation between schools • A different measure than used in any other indicator

The proposed regulations are attached. Recommendation to the Committee It is recommended that the Committee propose a draft A-F school accountability plan for grades K-8 that the Arizona Department of Education model and review with its advisory group, and provide feedback to the A-F Accountability Ad Hoc.

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For the reasons discussed in the preamble, the Secretary of Education proposes to amend parts 200 and 299 of title 34 of the Code of Federal Regulations as follows:

PART 200--TITLE I--IMPROVING THE ACADEMIC ACHIEVEMENT OF THE DISADVANTAGED

6. Section 200.14 is revised to read as follows:

§ 200.14 Accountability indicators.

. . . (c) A State must demonstrate in its State plan under section 1111 of the Act that each

measure it selects to include within an indicator under this section—

(1) Is valid, reliable, and comparable across all LEAs in the State;

(2) Is calculated in the same way for all schools across the State, except that measures within the indicator of Academic Progress and within any indicator of School Quality or Student Success may vary by each grade span; and

(3) Is able to be disaggregated for each subgroup of students described in §

200.16(a)(2);

(4) Is used no more than once in its system of annual meaningful differentiation under §200.18.

(d) A State must demonstrate in its State plan under section 1111 of the Act that each

measure it selects to include within the indicators of Academic Progress and School Quality or Student Success is supported by research that performance or progress on such measures is likely to increase student achievement or, for measures within indicators at the high school level, graduation rates.

(e) A State must demonstrate in its State plan under section 1111 of the Act that each measure it selects to include within the indicators of Academic Progress and School Quality or Student Success aids in the meaningful differentiation of schools under § 200.18 by demonstrating varied results across all schools in the State.

(Authority: 20 U.S.C. 6311(c); 20 U.S.C. 1221e-3)


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SUMMARY: The Secretary proposes to amend the regulations implementing programs under title I of the Elementary and Secondary Education Act of 1965 (ESEA) to implement changes to the ESEA by the Every Student Succeeds Act (ESSA) enacted on December 10, 2015. The Secretary also proposes to update the current ESEA general regulations to include requirements for the submission of State plans under ESEA programs, including optional consolidated State plans. Section 200.14 Accountability indicators

Statute: Section 1111(c)(4)(B) of the ESEA, as amended by the ESSA, requires each State to include, at a minimum, four distinct indicators of student performance, measured for all students and separately for each subgroup of students, for each school in its statewide accountability system. Although five types of indicators are described in the statute, only four indicators must apply to each public school in a State because two of the required indicators apply only to schools in certain grade spans.

• For all public schools in the State, section 1111(c)(4)(B)(i) requires an indicator of

academic achievement, based on the long-term goals established under section 1111(c)(4)(A), that measures proficiency on the statewide assessments in reading/language arts and mathematics required under section 1111(b)(2)(B)(v)(I). At the State’s discretion, this indicator may also include a measure of student growth on such assessments, for high schools only.

• For elementary and middle schools in the State, section 1111(c)(4)(B)(ii) requires an

indicator that measures either student growth or another valid and reliable statewide academic indicator that allows for meaningful differentiation in school performance.

• For all high schools in the State, section 1111(c)(4)(B)(iii) requires an indicator, based on

the long-term goals established under section 1111(c)(4)(A), that measures the four-year adjusted cohort graduation rate, and, at the State’s discretion, the extended-year adjusted cohort graduation rate.

• For all public schools in the State, section 1111(c)(4)(B)(iv) requires an indicator

measuring progress in achieving English language proficiency, within a State-determined timeline, for all English learners. This indicator must be measured using the English language proficiency assessments required under section 1111(b)(2)(G), for all English learners in each of grades 3 through 8, and in the grade in which English learners are assessed to meet the requirements of section 1111(b)(2)(B)(v)(I) to assess students once in high school.

• For all public schools in the State, section 1111(c)(4)(B)(v) requires at least one valid,

reliable, and comparable indicator of school quality or student success. Such an indicator may include measures of student or educator engagement, student access to and completion of advanced coursework, postsecondary readiness, school climate and safety, or any other measure a State chooses that meets the requirements of section 1111(c)(4)(B)(v). Section


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1111(c)(4)(B)(v)(I)(aa) requires that any school quality or student success indicator chosen by the State allow for meaningful differentiation of school performance, and section 1111(c)(4)(B)(v)(I)(bb) requires that the school quality or success indicator(s) be valid, reliable, comparable, and statewide (except that such indicator(s) may vary for each grade span).

Current Regulations: Various sections of the current title I regulations describe the measures used in the State accountability systems required by the ESEA, as amended by the NCLB.

Proposed Regulations: Proposed §200.14 would clarify the statutory requirements in the ESSA for States to include, at a minimum, four distinct indicators for each school that measure performance for all students and separately for each subgroup of students under proposed §200.16(a)(2).

Proposed §200.14(a)(2) would clarify that each State must use the same measures

within each indicator for all schools, except that States may vary the measures within the Academic Progress indicator and the School Quality or Student Success indicator or indicators by grade span as would be described in proposed §200.14(c)(2). Proposed §200.14 also would describe each of the five indicators that are required, at a minimum, as part of a State’s accountability system under section 1111(c) of the ESEA, as amended by the ESSA.

Academic Achievement Indicator

Proposed §200.14(b)(1) would:

• Require, for all schools, the Academic Achievement indicator to equally measure grade- level proficiency on the reading/language arts and mathematics assessments required under section 1111(b)(2)(B)(v)(I);

• Reiterate that the indicator must include the performance of at least 95 percent of all

students and 95 percent of all students in each subgroup consistent with proposed §200.15; and

• Clarify that, for high schools, this indicator may also measure, at the State’s discretion,

student growth based on the reading/language arts and mathematics assessments required under section 1111(b)(2)(B)(v)(I).

Academic Progress Indicator

Proposed §200.14(b)(2) would require, for all elementary and middle schools, the Academic Progress indicator to measure either student growth based on the reading/language arts and mathematics assessments required under section 1111(b)(2)(B)(v)(I), or another academic measure that meets the requirements of proposed §200.14(c).

Graduation Rate Indicator


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• Require, for all high schools, the Graduation Rate indicator to measure the four-year adjusted cohort graduation rate; and

• Allow States to also measure the extended-year adjusted cohort graduation rate as part of the Graduation Rate indicator.

Progress in Achieving English Language Proficiency Indicator


• Require, for all schools, the Progress in Achieving English Language Proficiency indicator to be based on English learner performance on the English language proficiency assessment required under section 1111(b)(2)(G) in each of grades 3 through 8 and in the grades for which English learners are assessed in high school to meet the requirements of section 1111(b)(2)(B)(v)(I);

• Require that the Progress in Achieving English Language Proficiency indicator take into

account a student’s English language proficiency level and, at a State’ discretion, additional student-level characteristics of English learners in the same manner used by the State under proposed §200.13; use objective and valid measures of student progress such as student growth percentiles (although the indicator may also include a measure of English language proficiency); and align with the State-determined timeline for attaining English language proficiency under proposed §200.13.

School Quality or Student Success Indicators


• Require, for all schools, the School Quality or Student Success indicator or indicators to meet the requirements of proposed §200.14(c); and

• Reiterate the statutory language that the indicator or indicators may differ by each grade

span and may include one or more measures of: (1) student access to and completion of advanced coursework, (2) postsecondary readiness, (3) school climate and safety, (4) student engagement, (5) educator engagement, or any other measure that meets the requirements in the proposed regulations.

Requirements for Indicator Selection

Additionally, under proposed §200.14(c), a State would be required to ensure that each measure it selects to include within an indicator:

• Is valid, reliable, and comparable across all LEAs in the State;

• Is calculated the same for all schools across the State, except that the measure or

measures selected within the indicator of Academic Progress or any indicator of School Quality or Student Success may vary by grade span;

• Can be disaggregated for each subgroup of students; and

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• Includes a different measure than the State uses for any other indicator.

Under proposed §200.14(d), a State would be required to ensure that each measure it

selects to include as an Academic Progress or School Quality or Student Success indicator is supported by research finding that performance or progress on such measure is likely to increase student academic achievement or, for measures used within indicators at the high school level, graduation rates. Finally, under proposed §200.14(e), a State would be required to ensure that each measure it selects to include as an Academic Progress or School Quality or Student Success indicator aids in the meaningful differentiation among schools under proposed §200.18 by demonstrating varied results across all schools.

Reasons: Given the new statutory requirements in the ESEA, as amended by the ESSA, and the increased role for States to establish systems of annual meaningful differentiation, we propose to revise the current regulations to reflect the new requirements and clarify how States may establish and measure each indicator in order to ensure these indicators thoughtfully inform annual meaningful differentiation of schools (described further in proposed §200.18).

Although the statute provides a brief description of each indicator, States will need

additional guidance as they consider how to design and implement school accountability systems that will meet their intended purpose of improving student academic achievement and school success. Because the indicators are used to identify schools for comprehensive and targeted support and improvement, including interventions to support improved student outcomes in these schools, it is essential to ensure that the requirements for each indicator are clear so that differentiation and identification of schools is unbiased, accurate, and consistent across the State.

Proposed §200.14(a) would reinforce and clarify the statutory requirement that all

indicators must measure performance for all students and separately for each subgroup of students, and that the State must use the same measures within each indicator for all schools, except for the Academic Progress indicator and the indicator(s) of School Quality or Student Success, which may use different measures among elementary, middle, and high schools. These proposed requirements would ensure that indicators include all students similarly across the State, including historically underserved populations, so that all students are held to the same high expectations. Further, these proposed requirements would ensure the indicators remain comparable across the State in order to promote fairness and validity, as schools will be held accountable on the basis of their students’ performance on each indicator.

While the proposed regulations would require all States to include all of the required

indicators, disaggregated by each subgroup, for annual meaningful differentiation of schools in the 2017-2018 school year, including the new indicators under the ESSA (i.e., Academic Progress, Progress in Achieving English Language Proficiency, and School Quality or Student Success indicators), we recognize that some States may want to update their accountability systems as new data become available. Accordingly, the proposed regulations would not preclude States from adding measures to their accountability systems over time that they

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currently do not collect or are unable to calculate, or from replacing measures over time, if particular measures of interest are not ready for the 2017-2018 school year, or if the State would like to gather additional input prior to including these measures in the accountability system for purposes of differentiation and identification of schools.

Academic Achievement Indicator Under section 1111(b)(2)(B)(ii) of the ESEA, as amended by the ESSA, State

assessments must provide information about whether individual students are performing at their grade level. This provides valuable information to students, parents, educators, and the public about whether all students are receiving the support they need to meet the challenging State academic standards and are on track to graduate college- and career-ready. It also ensures that students needing extra support to meet the challenging State academic standards can be identified--especially as school performance on the Academic Achievement indicator would be a substantial part of annual meaningful differentiation of schools under proposed §200.18 and identification of low-performing schools, including those with low-performing subgroups, for improvement under proposed §200.19. Accordingly, it is important to clarify that the measure of proficiency on those assessments included in the Academic Achievement indicator must reflect this grade-level determination, and that reading/language arts and mathematics must be equally considered within the indicator.

Progress in Achieving English Language Proficiency Indicator

In order for English learners to succeed in meeting the challenging State academic standards, it is critical for them to attain proficiency in speaking, listening, reading, and writing in English, as recognized in section 1111(b)(1)(F), including academic English proficiency (i.e., the ability to successfully achieve in classrooms where the language of instruction is English) as recognized in research and in the definition of “English learner” in section 8101(20).4 For these reasons, proposed §200.13 would clarify that States’ long-term goals should include both attainment of English language proficiency and annual progress toward English language proficiency for all English learners.

Similarly, proposed §200.14(b)(4) would clarify how a State measures progress in

achieving English language proficiency for all English learners for annual meaningful differentiation. The proposed regulation would provide States flexibility to develop a specific measure for this purpose, while ensuring that States use objective, valid, and consistent measures of student progress. Critically, the proposed regulations would require an objective and valid measure that English learners are attaining, or are on track to attain, English language proficiency in a reasonable time period, consistent with the State-determined timeline in proposed §200.13. As the Progress in Achieving English Language Proficiency indicator would receive substantial weight in annual meaningful differentiation under proposed §200.18 and could affect which schools are identified for support, it is important for States to design this indicator in ways that are valid and reliable and provide an accurate determination of English learners’ progress toward achieving proficiency in English. Finally, the indicator chosen by the State must include a student’s English language proficiency level, as well as additional student characteristics that are used, at a State’s discretion, in the English learner-specific long-term goals and measurements of interim progress, for the reasons

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discussed previously in proposed 200.13(c) and to provide consistency across the components of State accountability systems.

Requirements for Indicator Selection

Proposed §200.14(c) would reiterate that all indicators included in the accountability system must be valid, reliable, and comparable across all LEAs in the State, and that each included measure must be calculated in the same way for all schools. It would also prevent a State from using the same indicators more than once. For example, a State must choose a different indicator to measure school quality or student success than it uses to measure academic achievement.

Proposed §200.14(e) would require that the Academic Progress and School Quality or

Student Success indicator produce varied results across all schools in order to support the statutory requirements for meaningful differentiation and long-term student success. These proposed requirements are designed to ensure that the indicators provide meaningful information about a school’s performance, enhancing the information provided by other indicators and improving the ability of the system to differentiate between schools. In this way, the Academic Progress and School Quality or Student Success indicators can provide a more holistic picture of a school’s performance and, when selected thoughtfully, support a State in meeting the statutory requirement that these indicators allow for “meaningful differentiation.” The proposed parameters would help improve the validity of annual meaningful differentiation and support States’ identification of schools most in need of support and improvement. If a State chose an indicator that led to consistent results across schools--such as average daily attendance, which is often quite high even in the lowest-performing schools--it would not allow states to meaningfully differentiate between schools for the purposes of identifying schools in need of comprehensive and targeted support and improvement.

Finally, proposed §200.14(d) would ensure that a State selects indicators of Academic

Progress and School Quality or Student Success that are supported by research showing that performance or progress on such measures is positively related to student achievement or, in the case of measures used within indicators at the high school level, graduation rates. For example, a State might include at least one of the following School Quality or Student Success indicators that examine, for all students and disaggregated for each subgroup of students:

• “Student access to and completion of advanced coursework” through a measure of

advanced mathematics course-taking (e.g., the percentage of middle school students enrolled in algebra, or of high school students enrolled in calculus);

• “Postsecondary readiness” through a measure of college enrollment following high

school graduation or the rate of non-remedial postsecondary courses taken;

• “School climate and safety” through a robust, valid student survey that measures multiple domains (e.g., student engagement, safety, and school environment); or

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• “Student engagement” through a measure of chronic absenteeism based on the number

of students that miss a significant portion (e.g., 15 or more school days or 10 percent or more of total school days) of the school year.

Further, since measures of “postsecondary readiness” may not be available as an

indicator in elementary schools, a State could consider using an analogous measure in its accountability system, such as “kindergarten readiness” or another measure that would capture important outcomes or learning experiences in the early grades.

These requirements would support the purpose of title I--to “provide all children

significant opportunity to receive a fair, equitable, and high-quality education and to close educational achievement gaps”--by requiring States to use measures that are likely to close achievement gaps and are related to improvements in critical student outcomes. It would also create consistency across components of the accountability system described in proposed §200.12; the Academic Progress and School Quality or Student Success indicators would both provide additional information to help a State differentiate between, and identify, schools in a valid and reliable way, and also be relevant to its other indicators and support the State’s efforts to attain its long-term goals.

1 See, for example, Halle, T., Hair, E., Wandner, L., McNamara, M., and Chien, N. (2012). “Predictors and outcomes of early versus later English language proficiency among English language learners.” Early Childhood Research Quarterly Volume 27, Issue 1; and Graham, J. (1987). “English language proficiency and the prediction of academic success.” TESOL Quarterly, Vol. 21, No. 3, pp. 505-521.

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